DELTA MUTUAL, INC.
14362 North Frank Lloyd Wright Blvd., Suite 1103
Scottsdale, AZ 85260
February 28, 2012
Securities and Exchange Commission
Washington, D.C. 20549
| RE: | Delta Mutual, Inc. |
SEC Comment Letter dated February 24, 2012
Form 10-K/A for the Fiscal Year Ended December 31, 2010
Filed December 16, 2011
File No. 000-30563
Dear Sir/Madam:
We are submitting herein the responses of Delta Mutual, Inc. (the “Company”) to the comments set forth in your comment letter dated February 24, 2012 on the Form 10-K/A for the year ended December 31, 2010 (the “2010 10-K/A”), filed under the Securities Exchange Act of 1934, as amended.
Form 10-K/A for the Fiscal Year Ended December 31, 2010 filed on December 16, 2011
The Company is filing with this correspondence an amendment to the 2010 10-K/A that reflects the requested revision (in Comment No. 1) to the Madsen & Associates audit report and, in response to Comment No. 2, the reprinted report of Jewett Schwartz Wolfe & Associates that includes a legend indicating that the report is a copy of a previously issued report and that the predecessor auditor has not reissued the report.
The Company is responsible for the adequacy and accuracy of the disclosure in the filing.
The Company acknowledges that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing and that the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
The Company is also aware that the Division of Enforcement has access to all information we provide to the staff of the Division of Corporation Finance in your review of our filing or in response to your comments on our filing.
Sincerely,
DELTA MUTUAL, INC.
By: /s/ Malcolm W. Sherman
Malcolm W. Sherman
Executive Vice President
